I strongly oppose 18VAC85-120-110, which would permit athletic trainers to perform dry needling. Dry needling is not a superficial technique—it is rooted in acupuncture, a comprehensive medical system that requires thousands of hours of education in anatomy, physiology, diagnostics, and needling technique. Athletic trainers simply do not have the depth of training necessary to safely and effectively perform this invasive procedure. It is not enough to know how to insert a needle; without proper diagnostic training, there is a serious risk of misapplication and harm. In my clinical experience, I have treated numerous patients who experienced increased pain, dysfunction, or new musculoskeletal problems after receiving dry needling from inadequately trained practitioners from the physical therapy/sports therapy industry. Allowing this amendment to pass would jeopardize patient safety and devalue the complexity and origins of this powerful technique, so I urge you to prioritize patient well-being and stop this proposal. Thank you.